Nursing Home Motion 6 - Motion to Preclude Evidence

Memorandum in Support of Defendant Snow Valley's Motion in Limine #6 to Preclude the Use of Evidence to Be Used to Establish Loss of Society Not Previously Produced in Discovery

This Honorable Court should preclude Plaintiff from submitting into evidence, whether for demonstrative or substantive purposes, any photographs, mementos, or other objects to establish ROBIN PRAIRIE's loss of society of her grandmother, ANNA PRAIRIE. In the course of discovery, Plaintiff produced one photograph of herself with her grandmother. She did not produce any other documents or mementos relating to her relationship with her grandmother. Accordingly, it would be prejudicial for Plaintiff to Defendant's request for the production of documents and tangible things.

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